Habib Miah v. Morgan Stanley & Co. International PLC, et al.
S.D. New York · Oct 11, 2025
What happened in this matter?
The court identified that the pro se plaintiff used AI to generate filings containing fabricated case law and non-existent quotations. While the court dismissed the case for lack of subject matter jurisdiction, it formally recorded the plaintiff's reliance on AI-generated hallucinations as a troubling aspect of the litigation record.
- Why the court cared
- The court reasoned that the plaintiff's filings were unreliable due to the inclusion of fabricated citations and quotations, which the court identified as indicative of AI use, and further noted that the initial complaint contained residual AI-generated commentary.
- Why it matters now
- This case illustrates the risks of pro se litigants using AI tools to generate legal filings, resulting in the submission of fabricated authorities. It serves as a reminder for courts to scrutinize filings for AI-generated hallucinations and for practitioners to verify all cited authorities.
Why this matter is tracked
In a pro se employment dispute, the district court adopted a magistrate judge's report and recommendation to dismiss the plaintiff's complaint for lack of subject matter jurisdiction. During the proceedings, the defendants identified that the plaintiff's filings contained apparent AI-generated content, including fabricated case law citations and non-existent quotations. The court noted that the plaintiff's use of AI appeared to have begun with the initial complaint, which included residual text from an AI platform's response to prompts. While the court addressed the jurisdictional dismissal, it explicitly highlighted the plaintiff's troubling use of AI in its order, noting that the filings included citations to non-existent cases and quotations that did not appear in the cited authorities.
This case illustrates the risks of pro se litigants using AI tools to generate legal filings, resulting in the submission of fabricated authorities. It serves as a reminder for courts to scrutinize filings for AI-generated hallucinations and for practitioners to verify all cited authorities.
Record details
What the record establishes about AI use
The court noted the plaintiff's use of an AI platform.
The district court adopted the magistrate judge's report and recommendation in full, granting the defendants' motion to dismiss for lack of subject matter jurisdiction and denying the plaintiff's motion for leave to amend.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- False Quotes: Case Law | Defendants identified quotations in the filings that do not appear in the authorities cited; court observed these apparent false quotations as indicative of AI use.
- Fabricated: Case Law | Defendants identified a cited decision purportedly from the Eastern District of New York that does not exist; the court noted this as apparent AI-produced fabrication.
Questions this record answers
- What happened in Habib Miah v. Morgan Stanley & Co. International PLC, et al.?
- The court identified that the pro se plaintiff used AI to generate filings containing fabricated case law and non-existent quotations. While the court dismissed the case for lack of subject matter jurisdiction, it formally recorded the plaintiff's reliance on AI-generated hallucinations as a troubling aspect of the litigation record.
- Why does Habib Miah v. Morgan Stanley & Co. International PLC, et al. matter for legal AI risk?
- This case illustrates the risks of pro se litigants using AI tools to generate legal filings, resulting in the submission of fabricated authorities. It serves as a reminder for courts to scrutinize filings for AI-generated hallucinations and for practitioners to verify all cited authorities.
- What does the public record establish about Habib Miah v. Morgan Stanley & Co. International PLC, et al.?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Habib Miah v. Morgan Stanley & Co. International PLC, et al. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.